Jurisdiction(s):
United Kingdom

Exhibits to Witness Statements and Affidavits under CPR PD 32: form, organisation, voluminous/non-documentary items, defects, and filing (England and Wales)

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Practice notes

Preparation of exhibits to witness statements and affidavits

This Practice Note concentrates on assembling exhibits for witness statements and affidavits. It defines what an exhibit is and sets out practical matters to bear in mind during preparation, indicating where the requirements differ between witness statements and affidavits. It provides guidance on the form an exhibit should take, how to organise exhibit bundles, and how to address voluminous, defective and non‑documentary exhibits. Depending on the court for your claim, additional provisions may apply—see Court specific guidance. This Practice Note should be read with Practice Notes: Affidavits and witness statements supporting interim applications, Witness statements—substantive content, and Drafting witness statements—formalities and dealing with problematic witnesses.

An exhibit is made up of documents or other items used to support the contents of a witness statement or an affidavit. Exhibits are referred to within, but remain separate from, the witness statement or affidavit itself. An exhibit can consist of, for instance:

photographs
sound recordings
drawings
spreadsheets
correspondence
agreements
etc.

References to exhibits are found in CPR PD 32, para 11, CPR PD 32, para 14, CPR PD 32, para 18.3, CPR PD 32, para 18.4 and CPR PD 32, para 18.6...

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Web page updated on 21/05/2026

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